This program will focus on strategies that attorneys can use to best represent taxpayers under criminal investigation. Topics to be covered include elements of commonly prosecuted federal and state tax crimes, current IRS and DOJ tax prosecution initiatives, (particularly foreign bank account investigations), voluntary disclosures to state and federal authorities, reacting to the commencement of a criminal investigation, administrative vs. grand jury investigations, methods of proof, common defenses, attorney-client and joint defense issues, hiring accountants to assist defense counsel, whether to file (or amend) returns while under investigation, parallel civil IRS issues (including, offers-in-compromise and civil fraud penalties), expert testimony at trial, and sentencing advocacy issues under the United States Sentencing Guidelines.